EPA-420-S-77-108
Issue Paper
Lead Time Requirement for an Evaporative
Emission Standard of 2.0 g/test for Light Duty Vehicles and Trucks
June 1976
(Revision 11/77)
Michael W. Leiferman
Standards Development and Support Branch
Emission Control Technology Division
Office of Mobile Source Air Pollution Control
Office of Air and Waste Management
U.S. Environmental Protection Agency

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Lead Time Requirement for an Evaporative Emission Standard of 2.0 g/test
for Light-Duty Vehicles and Trucks
1.	Statement of the Problem
Is the implementation, of a nationwide 2.0 g/test evaporative emission
standard for light duty vehicles and trucks feasible for the 1980 model
year?
2.	Facts Bearing on the Problem
a.	In response to California's request for waiver with respect to
1977 evaporative emissions, several automotive manufacturers submitted
information in regards to lead time requirements for a 6.0 g/test standard.
Information submitted by GM is contained in the/ Appendix as Attachment
1, and information submitted by Ford is contained as Attachments 2 and 3
of the Appendix. This information, along with lead time considerations
submitted by Chrysler and AMC, is summarized and presented in Table I.
Major events in the vehicle certification schedule are also indicated.
Table I has been constructed with the assumption that an evaporative
standard will be implemented with the 1980 model year. Lead time re-
quirements are then based relative to start of 1980 model year engine
production.
b.	In their comments to the evaporative NPRM, manufacturers did
not submit detailed lead time information in regards to implementation
of a 2.0 g/test standard.
3.	Discussion
a. Table I compares the lead time requirements of the four larg-
est U.S. manufacturers in regards to a SHED evaporative standard imple-
mentation for the 1980 model year. The manufacturers agree quite closely
in regards to the Looling txi"e needed for making carburetor vent changes.
This lead time, which varies from 10 to 12 months, includes both inter-
nal and external vent modifications. Beyond the carburetor vent changes,
Ford indicated in May 1975 (Attachment 2 of the Appendix), that they
need to make major changes to their model 2700 carburetor. These tooling
changes have already been made for compliance with the 6.0 g/test stan-
dard. It is anticipated that lead time for carburetor vent modifications
is the longest tooling lead time requirement for a 2.0 g/test standard.
In May 1975, Ford also indicated that they would need to use EGR
cooling, requiring a tooling lead time of 22 to 24 months, to meet a 6.0
g/test evaporative standard. However, Ford has complied with the 6.0
g/test standard without EGR cooling and it is not expected to be used in
their 2.0 g/test systems.
^ "Comments in Response to the Notice of Proposed Rulemaking,
published in 40 Fed. Reg. 2022 et seq., dated January 13, 1976,"
Ford Motor Company, February 27, 1976.

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The manufacturers also agree reasonably well on the time required
for the production design, development, and testing before tooling can
begin. The estimates for the 3 largest manufacturers, as shown in Table
I, range from 7 to 9 months.
Prior to the production design, development and testing, the hard-
ware to be used on each vehicle-engine combination must be defined.
Since many 1978 emission certification vehicles and several modified
vehicles have given evaporative test results of less than 2.0 g/test,
the technical feasibility.of producing vehicles to meet this level has
already been demonstrated ' . Defining the required hardware for all
vehicles will be a process of applying the current technology to attain
an effective system for each vehicle-engine combination.
The amount of additional time required for defining the hardware is
dependent on several factors. Perhaps the major factor is the quantity
and quality of evaporative emission'control work which has already been
done by the manufacturers. Since a SHED evaporative standard of 6.0
g/test was implemented for the 1978 model year, all manufacturers have
already defined, designed, and tooled hardware for the 6.0 g/test
standard. This has developed much information which can be applied to
defining hardware for a 2.0 g/test standard.
GM, Ford and Chrysler have supplied the EPA with a sizable amount
of data from evaporative emission testing of various control system
configurations. Each of these three manufacturers have tested systems
which gave below 2 g/test (described in reference (3)). In addition,
vehicles modified and tested by Exxon Research and Engineering under
Contract No. 68-03-2172 (reference (2)) gave test results of less than
2 g/test, and many 1978 certification vehicle test results were under
2.0 g. So the hardware required for several vehicle-engine combinations
has already been defined. Continuing effort will be required to determine
which specific combination of hardware will be effective for other
vehicle-engine combinations. Although it is not expected that costly
modifications will be required, it will take some time to determine
which modifications are necessary.
Another important consideration in lead time requirement is cost of
the control system. If an inadequate period of time is allowed for
defining the hardware, the control system may be more complex and cost
more than necessary.
b. Because of essentially non-existent lead time estimates from
the manufacturers for a 2.0 g/test standard, the above analysis was
based on manufacturer lead time estimates for a 6.0 g/test standard.
(2)
Clarke, P.J., "Investigation and Assessment of Light Duty Vehicle
Evaporative Emission Sources and Control," Exxon Research and
Engineering, EPA Contract //68-03-2172, May, 1976.
(3)
"Technical Feasibility of a 2 g/test SHED evaporative Emission Standard
for Light Duty Vehicles and Trucks, Issue Paper by Michael W. Leiferman,
U.S. EPA, Ann Arbor, Michigan, June, 1976.

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If additional carburetor changes are necessary for the 2.0 g/test
standard, the tooling lead time for this modification should be no
greater than for the 6 g/test standard. Assuming that carburetor
machining changes will require the longest tooling lead time of all
equipment changes, tooling will need to begin by about June 1978 as
shown in Table I.
Automotive manufacturers have estimated that production design,
development and testing for a 6 g/test standard must begin 7 to 9 months
before tooling can begin. Due to the increased difficulty of meeting a
2.0 g/test standard, it would be expected that, without any prior SHED
test work, this phase of the program would take longer than 7 to 9
months. However, with implementation of the 6.0 g/test standard, consid-
erable experience has been gained by the manufacturers in regards to
designing systems to comply with a SHED test procedure. Considering
this prior experience, it is believed that a production design and
testing time of 7 to 9 months prior to hardware tooling for a 2.0 g/test
standard is reasonable.
Based on lead time estimates for tooling and production design,
development and testing, the date by which the manufacturers must have
defined carburetor changes is determined. As shown in Table I, a new
test standard for the 1980 model year would require that GM, Ford and
Chrysler have defined these changes by October 1977, November 1977, and
January 1978, respectively.
It is also informative to view lead time relative to the rulemaking
time table. In the event that carburetor changes are needed, most
manufacturers must have defined the hardware prior to expected rule
promulgation (March, 1978).
C. Status of Manufacturers as of November, 1977.
On January 13, 1976 the Notice of Proposed Rule Making for both the
6.0 and 2.0 g/test standard was published. When final rule making for
the 6.0 g/test standard was published (August 23, 1976), the original
regulatory action was divided into two separate rule making actions.
The August 23, 1976 publication stated that "final rulemaking for a
longer term evaporative emission standard is presently being considered"
and the 1978 ,standard will remain in effect for subsequent model years
"until revised". These and other statements in the August 23 publication
(as well as discussions between manufacturer and EPA representatives
which followed) enforced the EPA's position that a standard less than
6.0 g/test was being developed and would be promulgated when some issues
regarding its implementation were resolved. It was assumed that the
manufacturers would make valuable use of the additional lead time, since
they had stated in comments to the NPRM that more effective control
equipment needed to be designed and developed in order to meet a 2.0
g/test standard.

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At a EPA hearing in May, 1977 regarding California's request for
waiver of 2.0 g/test standard (with a 1.0 g/test allowance for non-fuel
emissions from data vehicles) in 1980, only three manufacturers (AMC,
Ford and GM) presented information concerning their development efforts
to achieve low evaporative levels. Considering the imminence of both
California and Federal regulations more stringent than the 6.0 g/test
standard, the level of effort by most manufacturers was not as high as
anticipated. The level of effort and current status of some of the
largest manufacturers are discussed below:
Ford - They basically supported the California request for waiver
of a 2.0 g/test evaporative emission requirement in 1980. At these
waiver hearings Ford presented test results from a program aimed at
identifying the source of and eliminating HC emissions from carburetors.
Their aggressive effort and success in developing effective evaporative
control system is demonstrated by the fact that 61% of the valid certi-
fication tests on Ford's 1978 certification vehicles (conducted at EPA's
Ann Arbor facility) gave results below 2.0 g. Ford is currently confi-
dent that about two-thirds of their present vehicles will meet a 2.0
g/test requirement with two modifications—(1) improved sealing and
gasket materials and (2) improved canister purging. They also expect
these two modifications to be adequate for the remaining .one-third of
their vehicles; however, this hasn't yet been determined
GM - They favored a nationwide standard in 1981 as opposed to a
California 2.0 g/test standard in 1980. They stated that a 2.0 g/test
standard was not technologically feasible for the 1980 model year.
Their lack of aggressiveness in developing 2.0 g/test control equipment
is demonstrated by the fact that Rochester Products did not start working
on the carburetor leak problem until this year (1977). Because of the
slow pace in development, GM has now stated that 20 months time is
required for them to obtain some of the equipment (air cleaner containing
activated carbon) which is needed to meet a 2.0 g/test standard.
Others - AMC presented a small amount of data at the California
waiver hearing and stated their dependency on the carburetor manufac-
turers for a "leak-proof" carburetor. Little or no information has been
submitted by any other manufacturers since comments to the NPRM; and
consequently their status in regards to lead time for a 2.0 g/test
evaporative standard is not known.
(A)
Information obtained in a phone conversation on October 19, 1977
with Donald Buist, Executive Engineer for Certification, Ford
Motor Company.
^ EPA Memorandum to the File entitled, "Meeting with General Motors
Concerning Lead Time Necessary for Implementation of a 2.0 g/test
Evaporative Emission Standard for Light Duty Vehicles and Light
Duty Trucks," November, 1977.

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Conclusion
Although some manufacturers may have little trouble meeting a 2.0
g/test requirement in 1980, others have made such little constructive
development effort that they would be faced with a high degree of risk
if such a standard were promulgated. In retrospect, if any lesson can
be learned from the development of the 2.0 g/test evaporative package,
it is that delaying rule promulgation to give manufacturers requested
time for development of control systems is an ineffective way of reducing
emissions.
If, as one manufacturer stated, 20 months lead time is now required
to obtain the necessary control equipment, a 1981 implementation date
would provide the necessary time for hardware design and tooling. A
1981 implementation date may also result in the use of some control
system components which would be more cost-effective and more durable
than those which might be used for 1980. For example, a 1981 implementation
date would hopefully allow manufacturers time to develop hot soak
control measures which will not require the use of equipment which needs
periodic replacement, such as engine air filters.
4. Recommendation
It is recommended that the proposed 2.0 g/test evaporative standard
be promulgated for the 1981 model year.

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Table I. Lead Time Considerations for a New SHED Evaporative Standard in 1980
M
. 1977 _
M| J | J
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1979
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Define Hardware
1 If	V
Typical Certification Schedule: Submit Start	Start
Part I Durability Data
Vehicles	Vehicles
GM
I
Define
Hardware
FORD
Production Design and Development
Tooling for Carb. Vent Changes
|Design and Development
| Tooling for Carb. Vent Changes
z
CHRYSLER
Z
AMC
Define Hardware
Define Hardware
Design and Development
Tooling for Carb. Vent Changes
1 Design & PevT~|
Tooling for Carb. Vent Changes
Start ]980
Engine Production
t

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APPENDIX
Lead-time Information Submitted by
Automotive Manufacturers in Regard to the
California Waiver Request for a
6 g/test Standard in 1977

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1977 EMISSIONS PROGRAM
TEST FACILITY & PROCEDURES
BACKGROUND TESTING
HARDWARE
DEVELOPMENT &
DURABILITY
DESIGN
PRODUCTION TOOLING
PRACTICE AMA
CERTIFICATION:
PART I SUBMISSION
DURABILITY VEHICLES
DATA FLEET
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PROPOSED CALIFORNIA EVAPORATIVE EMISSIONS PROGRAM

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Attachment 2
Ford Lead Time Information
The impact of the tooling lead time is summarized by passenger
car engine family in the following table:
Carburetor
Engine
Lead Time
EGR Cooler
Fuel Tank
Series/Months
2 2-24 Months
11 Months
2-3L 1-4
5200
/ 12
Not required
X
2.8L V-6
2700
/ 18
Not required
X
200 CID 1-6
YFA
/ 12
Not required
X
250 CID 1-6
YFA
/ 12
X
X
302 CID V-8
2700
/ 18
Not required
X
351W CID V-8
2150
/ 12
Not required
X
351M/400 CID V-8
2150
/ 12
X
X
460 CID
4350
/ 12
X
X

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19/7 SnFD TEST
CONTROLLING COMPC IT TOOLING TIME
(EXCLUSIVE OF CONCEPT FEASl^_jbITY AND PRODUCTION DESIGN)
1974
1975
1976
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8
7
6
5
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1

Samples
Due
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Carburetor - Major Change (18 Months)
Other Carburetors (12 Months)
EGR Cooler (22 - 24 Months)
Fuel Tanks (11 Months)
File
Part I
Start
50/000 Mile Testing
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1977 EPA Certification Timing
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